James R. Palmer and Linda D. Palmer - Page 21




                                       - 21 -                                         
        return (Schedule E), petitioners reported, inter alia, “Rents                 
        received” of $23,013 with respect to the Loomis residence.  The               
        $23,013 that petitioners reported in Schedule E as rent with                  
        respect to the Loomis residence included the $5,100 of Loomis                 
        residence monthly payments that Olin Ordnance reported in Form                
        1099 as part of the $52,894.31 of nonemployee compensation that it            
        paid to Mr. Palmer during 1995 pursuant to paragraph 5 and Exhibit            
        D of the Marion plant/Palmer consulting agreement.                            
             In Schedule C, Profit or Loss From Business, of the joint                
        return (Schedule C), petitioners reported in Part I, Income, gross            
        receipts of $47,794, which was the amount ($52,894.31) of                     
        nonemployee compensation that Olin Ordnance paid to Mr. Palmer                
        during 1995 and reported in Form 1099 reduced by the amount                   
        ($5,100) of Loomis residence monthly payments that petitioners                
        claimed in Schedule E as rent with respect to the Loomis resi-                
        dence.                                                                        
             In the notice of deficiency (notice) issued to petitioners               
        for the year at issue, respondent, inter alia, increased petition-            
        ers’ Schedule C reported gross receipts by $95,935 because respon-            
        dent determined that during 1995 Mr. Palmer had constructively                
        received that amount of nonemployee compensation from Olin Ord-               
        nance.11  Respondent also determined that the $5,100 of Loomis                


               11The $95,935 by which respondent increased petitioners’               
          Schedule C gross receipts for the year at issue because respon-             
                                                             (continued...)           





Page:  Previous  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  Next

Last modified: May 25, 2011